Press Releases
August 31, 2022

BMA Offers Solutions to Protect More than 29 Million Seniors and People with Disabilities in RFI Response to CMS

Coalition of 180+ stakeholder organizations and over 600,000 grassroots advocates delivers recommendations to build on health equity, affordability gains in Medicare Advantage

Washington, D.C.  – Better Medicare Alliance, the nation’s leading research and advocacy organization supporting Medicare Advantage, submitted comments to the Centers for Medicare & Medicaid Services (CMS) today in response to a request for information (RFI) on ways to strengthen Medicare Advantage.

“With a 94% consumer satisfaction rate, average annual consumer savings of nearly $2,000 per year, lower costs to taxpayers, and a proportionally more diverse beneficiary population, Medicare Advantage is paving the way for a healthier, more equitable future for America’s seniors and individuals with disabilities,” said Mary Beth Donahue, President and CEO of the Better Medicare Alliance. “We appreciate CMS’s call for input on ways to strengthen this valuable coverage lifeline and are pleased to share how Medicare Advantage is already delivering on the agency’s six-pronged strategic plan. As we outlined in our comments, it is critical that we build on the affordability and quality of care in Medicare Advantage for more than 29 million beneficiaries. We look forward to our continued partnership with CMS to that end.” 

In its comments, BMA offers recommendations to:

  • Advance health equity through public policies that help better identify and address social needs and risk factors and reduce gaps in care.
    • BMA encourages CMS to establish standards and processes for the collection of race, ethnicity, gender, and additional social determinants of health (SDOH) information in partnership with stakeholders.
    • BMA additionally supports promoting the use of Z codes to help better identify beneficiaries’ social needs and addressing SDOH in the Medicare Advantage Star Ratings quality measures.
  • Improve access to telehealth and virtual care in Medicare and Medicare Advantage by extending or making permanent flexibilities tied to the public health emergency.
  • Expand and permanently authorize the Medicare Advantage Value-Based Insurance Design (MA-VBID) model so Medicare Advantage can continue to offer tailored and innovative benefits that meet the whole health care needs of Medicare beneficiaries.
    • Participation in the MA-VBID model has grown significantly and is now projected to reach over 3.7 million beneficiaries this year. BMA recommends that CMS consider expanding model participation to include all Medicare Advantage plans, including Employer Group Waiver Plans (EGWPs).
    • In addition, CMS should consider permanent authorization at the end of the demonstration to promote continued investment in the innovations that require multi-year continuity for effectiveness.
  • Support, and effectively implement if enacted, bipartisan policies to strengthen Medicare Advantage, including increasing flexibility for plans to address social determinants of health and reforms to streamline and improve prior authorization.
    • BMA calls upon CMS to support bipartisan legislation like the Addressing Social Determinants in Medicare Advantage Act that would allow Medicare Advantage to offer certain supplemental benefits that are currently only available to chronically ill enrollees.
    • BMA also encourages CMS to support the Improving Seniors’ Timely Access to Care Act which builds on the Medicare Advantage community’s work to modernize prior authorization for beneficiaries while maintaining its role as a clinical tool to facilitate safe, evidence-based care.
  • Codify the 2016 best practices proposed in the CY 2016 Rate Announcement and Final Call Letter for health risk assessments (HRAs)
    • BMA believes in-home HRAs are an essential element of the high-quality, value-based clinical care model deployed in Medicare Advantage, and that all in-home HRAs should provide clinical care that meets beneficiary needs through a holistic approach.
    • In 2015, the Obama administration’s CMS encouraged “plans to adopt, as a best practice, a core set of components for the in-home assessments they perform.” BMA supports the codification of a robust set of best practices that stipulate who can perform in-home HRAs, what components must be included, and what processes exist for determining needed follow-up care.

More than 50 BMA Allies are expected to submit comments of their own expressing support for Medicare Advantage beneficiaries and offering solutions to safeguard the program for current and future seniors, including:

  • Asian & Pacific Islander American Health Forum (APIAHF), which calls upon CMS to “protect Medicare Advantage (MA), which is vital in addressing health disparities and expanding access to quality medical coverage and social benefits like transportation to provider visits and nutrition services to seniors across all populations.”
  • Arizona Nurses Association explains that Medicare Advantage “allows health care providers to deliver affordable, high quality, and comprehensive care and services to our nation’s seniors and patients with disabilities” and encourages CMS to “continue strengthening Medicare Advantage and ensuring that it is well positioned for long-term success.” The Association goes on to encourage “smooth, successful” implementation of the Improving Seniors Timely Access to Care Act when passed by Congress and encourages improved collection and dissemination of SDOH data and codification of best practices for in-home HRAs.
  • The National Black Nurses Association writes that “the Medicare Advantage program is working to address social determinants of health with innovative benefits that promote health and improve outcomes, in particular, for our most vulnerable African American seniors” and adds “Medicare Advantage provides affordable, high-quality, equitable and patient-centered coverage to populations our members serve.”
  • Meals on Wheels of Pasco County (Florida) notes that Medicare Advantage “positively contributes to our state’s growing elder community and organizations like ours by providing supplemental services, like meal delivery, to help our beloved, and often vulnerable, seniors and retirees live to their full potential.” The organization additionally calls upon CMS to “create uniform standards and processes for the collection of information related to race, ethnicity, gender, and other social determinants of health like food or housing insecurity” adding that this will “ensure that Medicare Advantage stakeholders are collecting and have access to consistent and reliable data which will allow health care providers to better serve their patients.”
  • Southern Nevada Building Trades Union writes that “the men and women who make our state more economically vigorous deserve programs like Medicare Advantage, an economically feasible alternative to traditional FFS Medicare.” It goes on to add that “CMS must continue strengthening this program and ensuring it is well positioned for long-term success.”
  • Teachers’ Retirement System (TRS) of Kentucky highlights the value of Medicare Advantage Employer Group Waiver Plans (EGWPS), noting that “With a Medicare Advantage EGWP, TRS has achieved stability with premiums, and the 2022 premium is less than the premium 20 years ago, with no material changes to the existing plan benefit design.” TRS of Kentucky goes on to urge CMS to “protect the EGWP waiver program to ensure our retired educators continue to have access to affordable, innovative health care benefits that are person-centered.”
  • Tivity Health explains that “MA plans frequently partner with national organizations like Tivity Health, which provides access to physical activity programs and social connections to millions of MA enrollees across the country through SilverSneakers” and adds that “Supplemental benefits, especially fitness benefits, play an important role in improving the health of MA enrollees.”
  • VNS Health raised the importance of Dual Eligible Special Needs Plans (D-SNPs) in Medicare Advantage, commenting that “MA plays an important role in delivering integrated care for dually eligible beneficiaries through D-SNPs. D-SNPs offer enhanced care management and coordination with Medicaid to address the needs of dually eligible beneficiaries.” The New York City-based health care provider recommends policy solutions including updating Medicare Plan Finder “to include new functionality and information on integrated care products.”

Read BMA’s full RFI response to CMS here.


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